Ellison v. United States

Summary

The District of Columbia Court of Appeals affirmed the denial of Rashad Ellison’s motion to suppress cocaine recovered after police observed an apparent hand-to-hand drug transaction. The court held that recovery of crack cocaine from the presumed buyer, combined with the observed transaction, supplied probable cause to arrest Ellison under the collective knowledge doctrine. It also held that Ellison’s three-minute pre-arrest detention was a reasonable Terry stop.

Holdings

1. The recovery of crack cocaine from the buyer, combined with the observed hand-to-hand transaction between the buyer and Ellison, supplied probable cause to arrest Ellison. Because the searches were conducted incident to that arrest and the government’s sequencing argument was unrefuted, the searches were supported by the Fourth Amendment search-incident-to-arrest exception.
2. On these facts, the collective knowledge doctrine permitted the court to impute to the arresting officer the directing officer’s later-acquired knowledge that crack cocaine had been recovered from the buyer.
3. Ellison’s approximately three-minute detention before probable cause accrued was reasonable under Terry and did not exceed the permissible scope of an investigatory stop.

Questions Presented

1. Whether officers had probable cause to arrest Ellison, thereby supporting the on-scene and stationhouse searches as searches incident to arrest.
2. Whether the collective knowledge doctrine permitted the court to consider the buyer's recovered crack cocaine in determining probable cause even though the arresting officer's personal awareness of that recovery was not established.
3. Whether Ellison's approximately three-minute pre-probable-cause detention was an unlawfully prolonged Terry stop.

Disposition

affirmed